Building Baselines: Kelly Crandall
As conversations around utility data access, distributed energy resources, and grid flexibility accelerate across the country, few people have seen the evolution of these issues from as many vantage points as Kelly Crandall. Now serving as Vice President of Regulatory and Policy at UtilityAPI, Kelly brings more than a decade of experience working at the intersection of energy policy, customer data, and market design, including roles in consulting, nonprofit advocacy, and most recently at the Colorado Public Utilities Commission.
In this conversation, Kelly reflects on what she’s learned moving between regulatory theory and implementation, why scalable customer-authorized data access has become foundational to the future of the grid, and what regulators, utilities, and third parties still underestimate about the systems needed to make that future work.
You’ve worked on energy data and regulation from multiple vantage points - consulting, nonprofit advocacy, utility-facing software, and most recently inside a state commission. How has moving between those roles shaped how you think about what actually works in regulatory design?
It has definitely made me much more pragmatic in how I approach policy and regulatory activities. There are political dynamics, timing constraints, statutory requirements, resource limitations, and strategy decisions specific to various parties. It’s given me the opportunity to see issues from multiple perspectives. How does commission direction translate to a utility program manager? How does a consulting recommendation get prioritized at a low-resource government agency? A policy recommendation might be conceptually good, but it has to be implementable within the unique characteristics of a particular state.
What did working inside a commission teach you about how data access decisions really get made versus how they’re often discussed externally?
First, everyone who is interested in regulatory work should spend time at a PUC at some point in their career! These agencies are full of incredibly dedicated people operating under challenging conditions.
Commissions have massive amounts of expertise, but “data access” is usually just one policy issue that regulators encounter within sweeping cases. This means that decisions on this topic are very dependent on the evidentiary record that gets created. Participation from people who have direct experience requesting and using data is critical for showing the value it creates to utility customers.
It’s made me very intentional about trying to go into proceedings and discussions with plain-language content and clear next steps. It’s easy to go down rabbit holes, which could put regulators in the position of having to referee technical topics that they aren’t comfortable with. A big part of my job is to educate so that regulators, utilities, and other stakeholders can increase their fluency around data access. But I also think a lot about how to frame the kinds of decisions that need to be made in different venues so that all stakeholders can focus their expertise in the right places.
Data platforms need to start being considered as foundational investments, like customer information systems, upon which diverse benefits can be built.
Your career has consistently sat at the intersection of policy goals such as energy equity, DER adoption, and grid modernization and the technical realities of data systems. Why do you think data access has become such a persistent throughline in your work?
I think a common thread has been expanding the perspective of regulators to consider policies where there is some interdisciplinary connection. Sometimes that means showing how utility data can be applied to other fields–like how statistics about energy usage can help local governments assess building code impacts. Other times it means bringing outside information into utility contexts, like educating utility regulators about what regulators at agencies like the Consumer Financial Protection Bureau have done with open banking data.
Moreover, data access is a microcosm for just about every intriguing topic within regulation right now, including all of these other policy areas I’ve worked on. It touches on competitive issues around who has rights to access and use certain types of data. It encourages utilities to look closely at customer experience and how to design tools that customers can easily use. It triggers questions about appropriate cost recovery, like user fees or performance incentives. It delves into technology questions like how utilities manage data in backend systems. Ultimately, it involves translating a lot of practical and technical issues for multiple audiences and through a law and policy lens.
Let’s dream a bit. Tomorrow, you wake up, and every utility can securely deliver accurate data for their customers and the built world when requested. Utility program owners can use it to empower and inform their programs. Customers and building owners can use it to make smarter decisions for their buildings. What are you most excited about and why? What else do you think is possible with this data access?
There’s a lot to be excited about. One of the fields I think could really benefit is weatherizing and upgrading housing. Right now, we see weatherization providers who have to fill out paper forms or set up special data-sharing agreements with utilities in order to serve residents whose income qualifies them for the Low Income Home Energy Assistance Program and similar assistance. Making data-sharing faster and simpler makes it easier for people to apply for programs that they might be eligible for and it lets program delivery teams focus on their core mission of making homes safer and keeping utility bills affordable.
And this is just a microcosm of the opportunity that data-sharing could open up for commercial real estate, retail stores, and municipalities. These are entities that can’t always invest in smart energy management because they’re spending resources on getting their bills organized for accounting. I think what you are freeing up is a massive amount of time and energy that can go toward making buildings more efficient, more comfortable, and even more capable of flexing their demand with grid needs.
At the end of 2025 (heading into 2026) you noted how much national attention utility data access has received and that activity has only accelerated. What do you think is driving this escalation, and how is the conversation different now than it was a few years ago?
When the topic of whether customers could share their data with third parties emerged early in the days of advanced metering deployment, there was a lot of discussion about potential opportunities for customers to manage their energy usage but there wasn’t always direct evidence that regulators could look to. The situation is very different now—there is much wider recognition that customers and distributed energy resource providers need frequent, accurate data to manage demand. With that opportunity, though, comes so many possible use cases that the conversations can be challenging in scope. Are we talking about interval data, grid data, program data? So we went from some limited examples to a huge universe of opportunities, which can feel overwhelming. We spend a lot of time talking to utilities and regulators about how there are certain data sets that are more important than others for particular use cases.
The major driver for data access conversations most recently has been the growing call for load flexibility, specifically virtual power plants and FERC Order 2222. Allowing distributed energy resource aggregators to participate in day-ahead energy and capacity markets will require a massive volume of data, provided very quickly, and without room for error. For example, PJM will be requiring DERAs to submit revenue-quality interval meter data within one business day (Participation Model Slides). We are moving into a future where we’ll need a consistent, accurate flow of meter and telemetry data across market entities.
What’s the biggest risk if this moment of heightened activity doesn’t translate into more consistent, scalable data access solutions?
There are two big types of risk that could come if we delay developing scalable data access. First, there are numerous studies indicating that demand-side flexibility can be deployed faster than new supply can be built. If we can’t build a market based on a shared understanding of customer usage and load flexibility performance, we may experience price spikes and reliability challenges, which will create trust gaps for utilities and regulators.
Second, the world of privacy and security is evolving. Currently, many utilities share data with contractors based on PDF forms. The customer isn’t necessarily authenticated using technology best practices like one-time passcodes. Or customers give contractors their passwords so that those contractors can scrape the information they need from utility websites. This creates a huge risk for customer privacy and for security of their account information–the prevalence of web-scraping has been one of the major reasons why open banking laws have gotten traction in more countries, including Canada. These laws move data-sharing into secure APIs so that customers don’t share credentials. The desire to increase privacy and security is one of the reasons that more utilities are investing in practices like multi-factor authentication for their own web portals, but these kinds of practices are just as applicable when customers are sharing data with vendors.
Across proceedings in places like New York, California, PJM states, and New England, we’re seeing many different use cases, DERs, VPPs, demand response, relying on the same core data. Why has it been so hard for regulatory processes to coalesce around shared, scalable data solutions instead of what we are seeing, which is bespoke solutions addressing a subset of needs?
First, utilities are facing a rapidly changing IT and security world, and their internal development resources are often spread thin. There isn’t always someone within the utility who is able to see across silos and recognize how multiple distributed energy resource programs could leverage the same data and tools. Any software project that involves interactions with customers or other external entities can be perceived as introducing risk which security teams need to mitigate, and sometimes traditional approaches to risk mitigation can negatively impact the value customers receive. Additionally, utilities manage and interact with many different software tools, so they have data stored in different locations. Figuring out how to bring that all together is pretty nuanced work that’s hard to do in a regulatory setting.
The second challenge is how regulatory proceedings are structured. Trying to tackle all possible third-party needs for data at once can be overwhelming. We focus on authorized data-sharing with individual customers, but some entities are really focused on distribution system data or anonymized data for public policy. Regulators need a strong vision to guide a proceeding like that and to stage work in a pragmatic way, rather than focusing on edge cases.
The alternative to holistic proceedings is focusing on data access in individual cases for specific purposes, but that might mean that the commission orders the utility to create a better tool for enrolling community solar customers in one context and a better tool for exchanging data with bill assistance providers in another context. Because the cases have different parties and different evidentiary records, no one recognizes they could build new functionalities onto the same basic tools. This kind of procedural siloing affects the perceived cost effectiveness of data platforms, because a platform that addresses multiple use cases is going to be more cost-effective than a platform that can only handle one. Data platforms need to start being considered as foundational investments, like customer information systems, upon which diverse benefits can be built.
You’ve emphasized VPPs and Order 2222 depend on high volumes of customers and fast, electronic data transfer. From your perspective, where are utilities and regulators most underestimating what’s required for that to work in practice?
People who don’t work regularly on software and information technology issues can sometimes underestimate their complexity. Because we work closely with utilities to pull data from different systems–customer information systems for account data, meter data management systems for interval data–we have an in-depth perspective on how challenging it can be to make that information match up. These kinds of systems may have been built a decade apart to address different purposes. The internal work it takes to be able to check an authorization, pull data from the right systems, consolidate it, and transform it into an appropriate format, can be extensive. Part of the value UtilityAPI brings is a decade of experience addressing this problem.
This sounds like a lot of work, but the flip side of the complexity of systems integration is that building those connections makes a lot of other programs and projects easier for the utility, beyond building a data platform. Once you’re able to coordinate interval usage and account data, it creates opportunities for time-varying rates and load flexibility. It can even make it easier for utility account managers and program administrators to identify candidates for deeper outreach. Maybe initially this work populates a platform where customers can share data with third parties, but it enables a lot of other opportunities.
There would be much greater recognition that customers have the right to access and share their own data, and the tools for that should look a lot like other industries. If I want to use Venmo, I don’t fill out a PDF form and send it to my bank. I securely link it to my bank account.
What is the role of user experience in customer-authorized data sharing, even beyond technical standards?
At one of my prior jobs, the human resources team would periodically require certain forms for compliance purposes. They always required us to fill out our start date, even though they identified us through other information. For years, I would have to double-check my calendar to put in the correct date.
Technical standards can make data transactions quick, secure, and accessible. When utilities provide data in standard formats like Green Button, it’s formatted to prevent data users from having to build systems to decipher each utility’s unique data fields. There are so many entities now, including retailers, aggregators, and real estate, that work with dozens of utilities in multiple states, so that is a real time-saver for them.
Layering user experience with technical standards is critical. Utilities are used to verifying customers in a certain way, like asking for account numbers, but that’s not what most modern online interactions look like. EnergyHub demonstrated how simple tweaks can improve user experience and lead to greater program enrollment without compromising customer privacy. In fact, by using software tools like APIs, user experience and privacy reinforce each other because customers can control what data is shared with which entities and for how long.
If we were to check back in at the end of 2026, what would success look like for utility customer data access in the U.S.?
There would be much greater recognition that customers have the right to access and share their own data, and the tools for that should look a lot like other industries. If I want to use Venmo, I don’t fill out a PDF form and send it to my bank. I securely link it to my bank account. Now I don’t have to pay fees to transfer money to a friend or family member who uses a different bank.
Once we think in that vein, I think we can get out of the habit of just looking at data-sharing as a checkbox that utilities have to comply with just because they installed advanced meters. Instead, it’s a value that they can offer their customers. Their customers can use this information to budget, meet climate goals, and even participate in retail and wholesale demand response. Key account managers can move beyond downloading billing data and start working with customers to solve bigger energy problems.
Finally, what’s one question you wish regulators were asking more often as they wade into data access issues?
Regulators have to take a very broad viewpoint because they’re considering the public interest. This means that they’re not just looking at impacts to utilities or utility customers, but also the outside entities that interact with the utility: independent power producers, retail suppliers, bill assistance providers. They may not regulate those entities, but those entities are critical to delivering safe, reliable, affordable, clean energy.
If we can move beyond compliance into thinking about how data access empowers customers to work with third parties, then by extension, we also need to think about the third-party experience and how they use customer data in their work flows. I would love to see regulators thinking about policy questions that impact third parties with an eye toward those entities being partners in the energy system. This involves asking questions like: Are utilities providing all of the data that third parties need to deliver the service the customer contracted for? Is that data accurate? Are third parties able to get registered? How can the utility leverage the same data exchange platform to serve more customer programs and get more efficiencies?
In doing this, regulators will also need to address consumer protections around third parties. Public utility commissions generally don’t regulate third parties like solar + storage companies–often, state attorneys general need to be involved. When it comes to data access, regulators may need to draw some careful lines that limit utilities’ liability for sharing authorized data with third parties and ensure customers have recourse with the appropriate legal entity. Commissions can play a valuable role by helping clarify these lines with the different entities involved–a much more productive place to be than limiting customers’ ability to share data because of ambiguity.
Fun Round
Tell us a little bit about what led you to your role with UtilityAPI.
My career has always involved data access policy, from working on energy management at the City of Boulder to advising local governments on benchmarking ordinances at the Institute of Market Transformation. I had been aware of UtilityAPI for almost a decade because of their reputation as a leading provider of Green Button Connect certified platforms. They were looking for someone with a regulatory background that could help them translate a very technical subject into policy venues across the country. I was fortunate because the job description felt like it was written for me!
What have you been reading lately?
I’m always working on at least one nonfiction and a couple of fiction books (often science fiction). For non-fiction, I just finished London Falling by Patrick Radden Keefe – his work was engrossing as usual as he tackled financial corruption and the reach of Russian oligarchs in London. For fiction, I just finished The Wayfinder, which is an amazing story that works on multiple timelines about Polynesian islands around 1,000 years ago. I have never read anything quite like it and it’s stuck with me. Currently I’m reading A Natural History of Dragons, which is written in the style of a Victorian explorer’s memoir. And I started The Vampire Lestat. Again. I’ve only gotten about half-way through Anne Rice’s Vampire Chronicles series, but Lestat is one of my comfort books and I keep going back to it because it is just so humanist in a weird way.
What’s one piece of advice you’d give to someone just starting out in energy policy who wants to work at the intersection of data, regulation, and markets?
Do informational interviews! Meet people across different parts of the industry at companies or jobs you might be interested in. When I was graduating law school and starting to look at energy for a career, I met with federal, state, and local government staff, utility staff, nonprofit representatives, legal and non-legal. I asked my new contacts who else I should be learning from. The process helped me focus my areas of interest, and I also made connections with people I still talk to at conferences or over coffee.
As Kelly makes clear throughout this conversation, utility data access is quickly becoming core infrastructure for the future energy system. From DERs and VPPs to customer experience and grid flexibility, the opportunities — and challenges — are only growing. Huge thanks to Kelly Crandall for taking the time to share her perspective and experiences with Building Baselines.
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